31 Days to a More Effective Compliance Program - Introduction to internal reporting and investigations

Thomas Fox
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The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a FCPA issue for your company. As the CCO, it will be up to you to begin the process which will determine, in many instances, how the company will respond. This chapter will provide you with the steps you will need to consider going forward.

This chapter will detail the two parts; internal See more +

The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a FCPA issue for your company. As the CCO, it will be up to you to begin the process which will determine, in many instances, how the company will respond. This chapter will provide you with the steps you will need to consider going forward.

This chapter will detail the two parts; internal reporting and investigations. It would seem axiomatic that organizations understand the benefits of having an internal reporting system, whether it is called a hotline, helpline or something else. Just as plainly, a company should understand the need for effective investigations after a report comes in which might lead to a potential violation.

Three key takeaways:

1. A robust internal reporting system will be one of the key indicia the DOJ considers.

2. Hotline reporting can bring a visibility to problems.

3. Hotline reports must be treated fairly and justly. See less -

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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